Support

Representation ID: 21287

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy CSP1 – Development Strategy

Draft Policy CSP1 (Development Strategy) provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039. Part 1a) states that at least 47,837 new homes will be delivered, creating sustainable mixed communities that are supported by adequate infrastructure. Part 2) of the policy outlines the spatial strategy which seeks to deliver this growth and sustainable patterns of development. Owl Homes is supportive of this proposed strategy, in particular the provision of new homes to meet housing needs. This is considered to be consistent with paragraph 20 (a) of the NPPF which requires strategic policies to make sufficient provision for housing.

Paragraph 35 (b) of the NPPF sets out that in order to be sound, a plan must be “justified’ – an appropriate strategy taking into account the reasonable alternatives, and based on proportionate evidence.” The subtext to draft Policy CSP1 (paragraph 3.7), advises that a range of alternative options were considered in deciding the proposed spatial approach, as demonstrated by the Spatial Options Paper. The chosen option (Spatial Option J – Balanced Growth) focuses growth within the existing Strategic Centres, Core Regeneration Areas and Towns and Neighbourhood Areas, alongside a limited number of new Neighbourhood Growth Areas near to the edge of settlements that take account of environmental, climate change, accessibility and socio-economic requirements.

The Regulation 18 Sustainability Appraisal (SA) outlines the range of benefits for the chosen option compared with the other alternative 10 options. The SA (Page 8) notes that the chosen option is “considered to perform the best, as it strikes a balance between retaining valuable environmental assets whilst also prioritising development in the most sustainable locations”.

It identifies minor positive outcomes in relation to landscape, biodiversity & geodiversity, climate change mitigation, transport, housing, equality, economy and education. Whilst the assessment notes potential minor negative impacts on waste, this is the case for all of the options, with the exception of option A (business as usual) and option b (employment-led growth) due to the uncertainties regarding the likely sustainability issues associated with waste generation. This demonstrates that the proposed strategy is the most justified and therefore sound approach, when compared with the other alternatives.

Paragraph 3.17 provides an overall summary of the strategy, which is that most housing growth and employment land development will be located in the existing built-up area, with additional homes and employment land allocated on sites removed from the Green Belt. The Council have acknowledged that there is a shortage of deliverable sites to meet housing and economic growth needs in the Black Country. Therefore, the Council’s proposed release of Green Belt land (including the Site) is supported.